EPA determined the Respondent failed to comply with its general duty, pursuant to Section 112(r)(1) of the CAA, (a) to identify hazards which may result from accidental releases of a regulated substance or other extremely hazardous substance, using appropriate hazard assessment techniques, (b) to design and maintain a safe facility taking such steps as are necessary to prevent releases, and (c) to minimize the consequences of accidental releases which occur. Respondent agrees, within sixty (60) days of the effective date of the Administrative Consent Order (the Order), to submit a detailed Work Plan with a schedule to identify and comply with all applicable codes, regulations, and industry standards and guidelines for anhydrous ammonia refrigeration systems. Also, Respondent will have a determination made of the total amount of anhydrous ammonia in the refrigeration systems at the Facility and address all the violations and safety concerns found in the May 2, 2016 inspection.